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This update addresses issues with pre-pop functionality, parent marital status, definition of "married," conflicting asset information, tax filing status, and IRS display flags.
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FAFSA℠ and Application Processing UpdatePresented by the Illinois Student Assistance Commission December 2013 Adapted from a presentation given by Ginger Klock and Misty Parkinson at the U.S. Department of Education’s 2013 FSA Training Conference
Link to drafts of all supporting documents and public comments
Pre-pop Functionality Issue A number of entities that interact with students have expressed interest in partnering with Federal Student Aid to further simplify the process of completing the FAFSA. Solution Approved partners will offer students the opportunity to pre-populate data collected by that partner (for example, a VITA site) into FAFSA on the Web.
New Parent Marital Status Issue Information about both legal parents is currently included on a dependent student’s FAFSA only if the parents are married to each other, creating an inequity. Solution A new parent marital status option of “Unmarried, but both parents living together” will allow for the collection of data from both legal parents when the parents are not married to each other. Mother and Father labels will change to Parent 1 and Parent 2. Help text will be significantly enhanced to provide guidance for parents who file separate tax returns.
Change to Definition of “Married” Issue The Supreme Court’s recent decision in United States v. Windsor changed the federal definition of marriage. Solution Text that defines marriage will be updated. Mother and Father labels will change to Parent 1 and Parent 2.
Conflicting Asset Information Issue If a student or parent answers “yes” to the asset threshold question but then reports assets that total less than the APA, it appears on the ISIR as conflicting information for the FAA to resolve. Solution An edit will be added to FAFSA on the Web that prevents this scenario from occurring.
Tax Filing Status Issue Inability to identify instances where the student’s or parents’ marital status conflicts with the tax filing status, resulting in the possibility that either too much income or not enough income is being reported on the FAFSA. Solution Students and parents will begin reporting their tax filing status on the FAFSA. The system will compare the tax filing status with the marital status to determine where potential discrepancies exist, and message accordingly.
IRS Display Flags Issue Some students and parents are not provided with the option to use the IRS DRT, and FAAs don’t know why. This makes it difficult to determine what documentation to ask for when the student is selected for verification. Solution New IRS Display Flags will be included on the ISIR, as well as in FAA Access. These alpha-character flags will identify the specific reason why a student or parent was not eligible to use the IRS DRT.
Blank = IRS DRT not available A = Dependent student skipped the income and asset questions – IRS DRT was not displayed B = IRS DRT was displayed to student C = Tax return status not equal to “Already completed” – IRS DRT was not displayed D = Marital status date greater than or equal to January 2014 – IRS DRT was not displayed E = First three digits of SSN are 666 – IRS DRT was not displayed H = Student amended his/her tax return – IRS DRT was not displayed J = Student filed a Puerto Rican or Foreign tax return – IRS DRT was not displayed K = Student is married and tax return filing status is Married Filed Separate Return – IRS DRT was not displayed L = Student is married and tax return filing status is Head of Household – IRS DRT was not displayed M = Conflict between the student’s marital status and tax return filing status – IRS DRT was not displayed IRS Display Flags - Student
Blank = IRS DRT not available A (if student is dependent) = Dependent student has special circumstances – IRS DRT was not displayed A (if student is independent) = Independent student skipped the parent questions – IRS DRT was not displayed B = IRS DRT was displayed to parent C = Tax return status not equal to “Already completed” – IRS DRT was not displayed D = Marital status date greater than or equal to January 2014 – IRS DRT was not displayed E = First three digits of SSN are 666 – IRS DRT was not displayed F = Non-married parent or both married parents entered all zeroes in SSN – IRS DRT was not displayed G = Neither married parent entered a valid SSN – IRS DRT was not displayed H = Parent amended his/her tax return – IRS DRT was not displayed J = Parent filed a Puerto Rican or Foreign tax return – IRS DRT was not displayed K = Parents are married and tax return filing status is Married Filed Separate Return – IRS DRT was not displayed L = Parents are married and tax return filing status is Head of Household – IRS DRT was not displayed M = Conflict between the parents’ marital status and tax return filing status – IRS DRT was not displayed N = Parents’ marital status is “Unmarried and both parents living together” – IRS DRT was not displayed IRS Display Flags - Parent
Messaging for Corrections Issue Some students and parents return to FAFSA on the Web to use the IRS DRT, add a school code, or make other corrections, but don’t submit those corrections. Solution Messaging that displays will be modified when a user returns to FAFSA on the Web after transferring data from the IRS. Additionally, an e-mail will be sent to students with a saved correction after seven days of inactivity, encouraging them to return to FAFSA on the Web and submit the corrections.
Increased Field Lengths Issue The number of characters allowed in the student and parent financial fields needs to be changed in order to accurately report income and EFC for high cost institutions with high income students. Solution Increase lengths of all income and asset fields and calculated EFC values to allow for more characters.
150% Subsidy Loan Limit Issue On July 6, 2012 President Obama signed into Public Law 112-141, the elimination of the subsidy on Direct Subsidized Stafford Loans when a “new borrower’s” enrollment exceeds 150% of the published program length (DCL: GEN-13-13). Challenges Upon receipt of a Direct Loan actual disbursement with a first disbursement date on or after July 1, 2013, COD must determine if the borrower meets the definition of a “new borrower” to confirm that the 150% subsidy limit applies to the borrower.
150% Subsidy Loan Limit Solution • Identify “new borrowers” starting July 1, 2013 (Phase 1) • Identify when a borrower reaches the 150% threshold and take appropriate actions (Phase 2) • Continuously monitor “new borrowers” enrollment to evaluate future enrollment impacts to students’ 150% limitations (Phase 2) A “new borrower” is defined as any borrower without an outstanding loan balance on July 1, 2013 or thereafter (Direct Subsidized, direct unsubsidized, PLUS loan [parent PLUS and grad PLUS], FFEL, consolidation and/or converted TEACH).
150% Subsidy Loan Limit The following NSLDS fields will be added to the ISIR: • These fields will be passed from NSLDS to CPS starting with 2014-2015 at the borrower level during pre-screening • A SAR Comment 267 will be triggered when SULA Flag is set to Y • New NSLDS Post-Screening Reason Code 25 value will be added: Subsidized Usage Applies Flag Status Change • https://federalregister.gov/a/2013-11515(DCL: GEN-13-13)
150% Subsidy Loan Limit • SAR Comment 267 • There is a limit to the total amount of subsidized federal student loans that you may receive. Please visit Studentaid.gov and select Types of Aid/Loans for more information. • Reason Code 25 will be added to the NSLDS Post-screening for a Subsidized Usage Limit Applies Flag status change.
Update NSLDS Fraud Loan Flag Issue NSLDS receives records from the Office of Inspector General (OIG) that indicate someone has been convicted of fraudulently obtaining federal loans and is no longer eligible for aid. Solution Beginning January 1, 2014: • NSLDS records that receive a flag value of “Y” in the NSLDS Fraud Loan Flag field will no longer have a SAR C Code • Records will now receive Reject Reason 24 and SAR Comment 272 • Effective for 2013-14 and 2014-15
Update NSLDS Fraud Loan Flag • SAR Comment 272: • The National Student Loan Data System (NSLDS) indicates that you have one or more student loans that may have been obtained fraudulently. You are not eligible to receive any federal student aid until this issue is resolved.
Applicants Younger than 13 Issue Provide a COPPA-compliant process to allow students younger than 13 to apply for Title IV. Solution • Implement a special-handling paper process that: • Will bypass the Date of Birth edit • Will not allow the student to provide an e-mail address • Student will receive a paper SAR and the school will receive an ISIR • The Renewal Process will not be available for these applicants
Applicants Younger than 13 Correction Process • If corrections are required, • the student/parent can submit them via the paper SAR correction process • The FAA can make corrections, except they cannot provide an e-mail address
IRS Data Retrieval Tool • Embedded link within FAFSA on the Web • Applicants must successfully authenticate using information from the filed tax return • Tax return data is available only after the return has posted to the IRS system • Retrieves specific tax return data from an originally filed tax return and displays data on applicants’ browser • Upon request, transfers the displayed data directly in response to specific questions on the FAFSA • IRS Transcript usually not required if data is successfully transferred and not modified by applicant • 2014 changes include Language toggle link, display of filing status and “per computer” values 36
IRS Transcripts • Tax Return transcripts - Anyone who filed a tax return, including first time filers • Tax Account transcripts • Anyone who filed a tax return/amended return, including first time filers • Record of Account • Anyone who filed a tax return/amended tax return, including first time filers • Verification of Non-filing • Non-filer; letter not a transcript • Information Returns Transcripts (W-2, 1099, 1098, 5498) • Anyone who has income that was reported to the IRS • Tax Return Database View (TRDBV) • Taxpayer who filed an original tax return and can not get a normal transcript through other methods because of duplicate tax return posting 37
IRS Transcripts • Basic information from tax return • Line by line presentation of tax return 38
IRS Transcripts: Availability • Electronically filed Tax Returns • $0 balance/refund returns: Generally available 2-3 weeks after the return has been accepted by IRS • Balance due/partial pay returns: Generally available by end of June or 3-4 weeks after the IRS receives the full/final payment • Paper Tax Returns • $0 balance/refund returns: Generally available 8-11 weeks after the IRS receives the return • Balance due/partial pay returns: Generally available by end of July • Amended Returns • Must be filed as a paper return • Generally available 12 weeks after the IRS receives the amended return • ID Theft Cases • Must be filed as a paper return • Generally available 8-11 weeks after the IRS receives the duplicate return 39
IRS Transcripts – Get Transcript • Get Transcript is a new IRS online service that will provide an electronic PDF version of official IRS Transcripts, launching early in the filing season 2014 • Key features: • For individual filers • Delivers all available Transcript types and/or Letters of Non-Filing • Accessible after taxpayers authenticate • Provides immediate display of transcript via PDF file; users can view, print, and save the file • Get Transcript is IRS’s preferred Transcript delivery channel • www.irs.gov/transcript 40
Get Transcript • Step 1 (Optional): Choose reason for requesting transcript. Receive suggestion • Step 2: Access available Transcripts and/or Letters of Non-Filing, organized by type 41
Other IRS Transcript Options • Transcript Toll free telephone line • Self service; 5-10 calendar day delivery to the address on file • 1-800-908-9946 • IRS2Go • Self service; mobile app; 5-10 calendar day delivery to the address on file • Available for Android and iOS (Apple) mobile devices • Order a Transcript • Self service; web app; 5-10 calendar day delivery to the address on file • http://www.irs.gov/Individuals/Order-a-Transcript • Form 4506-T • Manual process; up to 10 business days to process request and send transcript to the specified address • Third party address identified on Line 5 must be very specific 42
2014-15 Verification • Federal Register Notice, published June 13, 2013, Free Application for Federal Student Aid (FAFSA) Information To Be Verified for the 2014-15 Award Year • Dear Colleague Letter GEN-13-16, Published June 13, 2013, 2014-15 Award Year: FAFSA Information to be Verified and Acceptable Documentation
2014-15 Verification • Retained all items subject to verification in 2013-14 • Added one new item-- • Other untaxed income and benefits
2014-15 Verification • Documentation of untaxed income and benefits • Untaxed income information reported in Question 45 for the student and spouse and Question 94 for the dependent student’s parents • If the verified income does not appear to provide sufficient financial support, the student or parents must explain how the family was supported during the 2013 calendar year
2014-15 Verification • Small number of students will be selected to verify household resources • Provided extensive sample verification text that may be used for verification • Three pages that collect more detailed information on Q45 and Q94 • One page that collects optional additional information • Rely on the FAA to make the determination that the family had sufficient resources
Verification Data from January 1, 2013 to November 1, 2013 Verification Selection • Indicate of the 5,722,505 selected for verification from the 18,827,577 who applied to date • .9% (51,533) were placed in the V4 – Customized Verification Group • 1.45% (82,889) were placed in the V5 – Aggregate Verification Group Unusual Enrollment History (Not part of Verification) • Indicate of 18,827,577 who applied to date • .93% (175,567) were placed in the UEH Flag #2 category • .14% (26,496) were placed in the UEH Flag #3 category
Verification Issue FSA continues the process of refining verification selection efforts related to Identity criteria (V4 and V5) based on data analysis, resources and reporting tools. Enhancements • New Reject Reason 23 will be applied when certain conditions related to identity issues are met • SAR Comment 281 will be generated • Reject 23 can only be overridden by FSA • A system-generated SAR will be sent with SAR Comment 283